ML19343D386

Forwards Applicants Testimony & Exhibits to Be Presented at Proceeding Starting 810512.Applicants Will Seek Stipulation on Admissibility of Exhibits.W/O Testimony.Certificate of Svc Encl.Related Correspondence

ML19343D386
Person / Time
Site:	South Texas
Issue date:	04/23/1981
From:	Newman J LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	Bechhoefer C, Eva Hill, John Lamb Atomic Safety and Licensing Board Panel
References
NUDOCS 8105040391
Download: ML19343D386 (8)

Text

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Ib0I' April 23, 1981 o PETER 4.9LYNN p, g [% \\p*\\ STEVEN p. f 4 ANTI

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FREDERIC S. 3A AT akven w.GuvTERMAN . / Davec S. PowELb' DaveO m. maansas o) OCNALO A. SatytmesaN

• aou a sas Charles Bechhoefer, Esquire Chairman 4

N Atomic Safety and Licensing Board

5t3 U.S. Nuclear Regulatory Commission 6

4 Washington, D.C. 20555 C @P gpg 37 Dr. James C. Lamb d the S } ghdoi 313 Woodhaven Road II*g Chapel Hill, North Carolina 27514 b, p Ernest E. Hill Lawrence Livermore Laboratory University of California P. O. Box 808, L-123 Livermore, California 94550 Gentlemen: i i Enclosed are copies of the following testimony to be presented on behalf of Applicants at the phase of this proceeding scheduled to begin on May 12, 1981: (1) Testimony of Mr. Don D. Jordan on HIIxP's corporate commitment to the safe construction and operation l of STP; l (2) Testimony of a panel consisting of Mr. Jerome H. Goldberg and Mr. Richard A. Frazar on HL&P's management of STP; 1 >s10534^ W

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Lowaxcuzx, Newxur, Rzzo & Axzz. man Page 2 (3) Testimony of a panel consisting of Mr. George W. Oprea, Jr., Mr. Joseph W. Briskin, Mr. Richard A. Frazar and Mr. John M. Amaral on the experience of HL&P in the construction of STP and the actions taken as a result of the NRC Order to Show Cause thereof; (4) Testimony of a panel consisting of Dr. Knox M. Broom, Jr., and Mr. Raymond J. Vurpillat on B&R management and STP QA program; (5) Testimony of a panel consisting of Mr. ' Gerald R. Murphy, Mr. Ralph R.. Hernandez and Mr. Joseph F. Artuso on the concrete verification program; (6) Testimony of a panel consisting of Mr. Gerald R. Murphy, Mr. Gerald L. Fisher, Mr. Charles M. Singleton, Mr. Ralph R. Hernandez, Mr. David G. Long, and Mr. Joseph F. Artuso on several activities comprised within or related to the STP concrete work, and the contentions of the intervenors which relate to these activities (Contentions 1(2), 1(3), 1(4), 1(5), and 1(6)); (7) Testimony of a panel consisting of Mr. Albert D. Fraley, Mr. Gordon R. Purdy and Mr. Robert A. Carvel on the concrete restart program; (8) Testimony of a panel consisting of Mr. C. Bernt Pettersson, Mr. Timothy K. Logan, Mr. Charles S. Hedges, and r+-- _.., - - ~. _ - -. _, ~.,. _. -. -,. - -. - -.,,. _ _ _.,,,, _. - - _ - -, _., _ -, - -,,, _,,,

Lc,wcNarztz, NzwwAx, Rzra & AxzI.OAD Page 3 Mr. W. Stephen McKay on the structural backfill program at STP; (9) Testimony of a panel consisting of Mr. Stanley D. Wilson and Mr. Thomas E. Kirkland on the evaluation of category 1 structural backfill at STP; (10) Testimony of a panel consisting of Mr. C. Bernt Pettersson and Mr. Jon G. White on the alleged false statements in the FSAR; (11) Testimony of a panel consisting of Mr. Eugene A. Saltarelli, Mr. M. D. Muscente, Mr. Gordon R. Purdy, Mr. J. Rodolfo Molleda, Mr. Logan D. Wilson, Mr. Michael Sullivan and Dr. Daniel Hauser on the welding program at STP; (12) Testimony of Mr. Richard W. Peverley on Intervenors' Contention 1(1); (13) Testimony of Mr. Richard W. Peverley on the role of QC Inspectors in verifying design changes and the qualification of personnel approving design changes (Part of contention 1(7)(a); and contentions 1(7)(b) and 1(7)(c)); (14) Testimony of a panel consisting of Mr. G. Thomas Warnick, Mr. Charles M. Singleton and Mr. Logan l D. Wilson on alleged thwarting of communications between QC Inspectors and Design Engineers, alleged falsification of pour cards and alleged harassment and intimidation of QC i ,.,.n

Low =xc1xxx, NzwwAx, R=za & Axxx. nan Page 4 Inspectors (Part of Contention 1(7)(a); and Contentions 1(7)(d) and 1(7)(e)); (15) Testimony of a panel consisting of Mr. W. Stephen McKay and Mr. Timothy K. Logan on alleged incidents of document falsification (Part of Contention 2); and (16) Testimony of a panel consisting of Mr. Richard Buckalew and Mr. John B. Duke on alleged falsification of Cadweld records (Part of Contention 2). As the Board will note, the panel of witnesses presented on welding differs slightly from those identified in my letter to the Board of March 2, 1981. Since Mr. T. J. Natarajan, B&R's Materials Engineering Manager, has taken on new responsibilities that require significant overseas work, he has been replaced on the panel by Mr. Eugene A. l Saltarelli, Senior Vice President and Chief Engineer of the I l B&R Power Group. Mr. Saltarelli also replaces Mr. James l' L. Hawks, B&R's Engineering Project Manager, who is in a position reporting to Mr. Saltarelli. The final change in the panel involves the addition of Dr. Daniel Hauser, Program Manager at Battelle Columbus Laboratories, which has been selected to perform the evaluation of the inaccessible AWS structural welds at STP. Although my letter stated that there would be two witness panels on welding, as the testimony

I1wzxsistx, NzwxAx, Rzza & AxzutAn Page 5 was being written it became apparent that it was not practical to separate the testimony. Accordingly our testimony includes only one witness panel on welding to address all of the matters described in my letter. Applicants have recently been informed by the NRC Office of Inspection and Enforcement of the results of the investigation it conducted as a result of the tape that was provided by the intervenors to I&E. We have not had an opportunity to deal with such matters in the testimony being filed today, but will do so either in oral testimony at the hearing or in supplementary written testimony. In addition to the enclosed testimony (including i the attachments enclosed therewith), Applicants intend to present into evidence a number of exhibits. These will i include the following: (1) Letter to Mr. Karl V. Seyfrit dated December 28, 1979 (ST-E-AE-401). (2) Letter to Mr. Karl V. Seyfrit dated January 25, 1980 (ST-E-AE-409 ). (3) Letter to Mr. Karl V. Seyfrit dated February 7, 1980 ( ST-E-AE-417 ). (4) Letter to Mr. Karl V. Seyfrit dated February 28, 1980 ( ST-E-AE-425 ). l

Lownwararx, NzwxAx, Rs:s & Axzz.aAn Paga 6 (5) Letter to Nuclear Regulatory Commission dated May 23, 1980, with attachments, including Applicant Houston Lighting & Power Company's Reply to Notice of Violation. (6) Licensee's Response to Order to Show Cause, with attachments, submitted to the Nuclear Regulatory Commis-sion under letter dated July 28, 1980. l (7) " Final Report of the Review of Safety Related concrete", submitted to Mr. Karl V. Seyfrit under letter dated April 9, 1981. (8) " Expert Comnittee's Final Report on Adequacy of Category I Structural Backfill South Texas Project Electric Generating Station", submitted to Mr. Karl Seyfrit under letter dated February 27, 1981 (ST-HL-AE-625). (9) " Review of Safety Related Welding At South Texas Project Electric Generating Station", Final Report to be submitted to NRC Office of Inspection and Enforcement, Region IV and served on all parties in April 1981. t (10) Revised Houston Lighting and Power Company quality assurance program description,. submitted under ( letter to Mr. Robert L. Tedesco dated April 22, 1981. Copies of proposed exhibits 1, 2, 3 and 4 are enclosed. Copies of proposed exhibits 5, 6, 7, 8, and 10 were served on the Board and the parties when they were filed with the NRC. ~..

L wzxnzzx, NzwxAx, Rzza & Axzzz:An 9 Pago 7 Copies of exhibit 9 will be served on the Board and 'the parties when it is completed and submitted to NRC. Additional copies will be availe.ble at the hearing when the exhibits are presented. Since Applicants understand that the NRC Staff I will seek to have the parties agree to a stipulation concerning the admissibility of the NRC Staff's exhibits, Applicants will seek a similar stipulation for their exhibits. Respectfully submitted, J M

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Of Counsel: Lowenstein, Newman, Reis & Axelrad 1025 Connecticut Ave. N.W. i Washington, D.C. 20036 1 Baker & Botts 3000 One Shell Plaza Houston, Texas 77002 I Attorneys for HOUSTON LIGHTING & POWER I COMPANY, Project Manager of the South Texas Project, acting herein on behalf of itself and the other Applicants, CITY OF SAN ANTONIO, TEXAS, acting by and through the City Public Service Board of the City of San Antonio, CENTRAL POWER AND LIGHT COMPANY and CITY OF AUSTIN, TEXAS. TH:11:E l

i p e # g g cS t 0000457 4 Houston Applicants' Exhibit No. 1 7 ComJany December 28, 1979 l Electnc Tower ST-HL-AE-401 POBox 1700 SFN: V-0110 i l t Houston. Texas 77001 e k s Director, Region IV g coega7so g Office of Inspection and Enforcement uma 611 Ryan Plaza Drive, Suite 1000 2 1 Arlington, Texas 76102 8-APR 271981 > -2 Off;ca cfits $2:@/ Catletinz 15 mica y k Bata

Dear Sir:

South Texas Project o Units 1 & '2 Docket Nos. STN 50-498, STN 50-499 'n In confirmation of our meeting this day, December 28, 1979, relative to the South Texas Project QA Program the following action items will be ~ implemented: y o 1. Brown & Root will hold a seminar on January 4,1980, to review with Construction and QC personnel the fundamental philosophies and standards C of our QA Program with emphasis on the roles played by the respective personnel and the underlying purpose of the Program, which is to ensure. g that we build a plant which can be safely operated. ao 2. Procedure changes will be made to clarify the use of Field Requests N for Engineering Action (FREA's) and Non-Conformance Reports (NCR's). Retraining for Construction and QC personnel in the use of these O procedures will be held on January 10, 1980. 3. Brow 1 & Root will issue a written policy which embodies the process of problem solutions, and lays out specific steps to be taken when disagreements between personnel' arise so that those disagreements may be properly dispositioned. The policy will specifically address the fact that threats will not be tolerated. 4. A management assessment of the overall qualifications of the Brown & Root QA and QC personnel will be completed by the end of January,1980, to provide the basis for upgrading the caliber of personnel. Our personnel will be involved in this evaluation with Brown & Root management. 5. The thoroughness of procedure implementation in regard to concrete pre-planning and placement activities will be increased by express direction to Brown & Root QA and Construction Management and the implementation of that direction will be ensured by participation and Ottl'6 o F 6 003 PM 4 5

Houston ts)nng & Pour Company involvement in the pre-planning and placement process by our Construction and QA personnel, jointly acting to represent our interest in making sure of complete thoroughness. 6. Procedures will be revised to provide a controlled method for judging when reinspection of a concrete placement is aecessary prior to sign-off of the pour card. Retraining in the procedures will be held.on January 3, 1980. 7. Mr. W.N. Phillips and two other key members of our QA staff have been assigned to the jobsite to fortify our role in the short-term and to be directly and visibly involved in the work in the field and to better support the continuing investigation / inspection by the NRC staff. We will also add additional permanent staff to the jobsite in 1980 as resources to continue in a much more involved and participative role to ensure the procedures are adequate in themselves and that implementation is thorough. Distinctive identification will be provided for our personnel so that their presence will be known to all parties either observing or participating in the work. to 8. A program of refresher training will be implemented to ensure continuous revitalization of the knowledge of Construction and QC 'O personnel relative to their assigned duties and procedures governing their work. y 9. An assessment will be made starting with top level management and proceeding throughout the Brown & Root organization to determine the cause o of the perception of harassment or undue pressure on QC personnel. Changes will be made as results of the assessment are clear and conclusions can be O drawn. We expect to complete this assessment within thirty days. O Per our discussion w intend to continue placing non-complex safety O related concrete. You recall that we classify all safety related concrete as complex and non-complex. All RCB shell concrete is classified as complex. The N criteria for classifying the concrete is arrived at jointly by field engineering, construction supervision and QA/QC by considering the rebar o density and configuration; quantity and size of embeds; and pour volume, o geometry and location. We will keep you informed of the status of the action items, assessment program and any additional alternatives that become appropriate. l Very rs, E$ecu ' ve Vi sident GWO/mi cc: E. A. Turner D. G. Barker l R. A. Frazar 1 i 1 1

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vusTcx LIoHTINO & Powra CoMPANT R O Box 17oo Houstees.Tmus 77001 j, " *d*,",,,,

January 25 1980 ST-HL-AE-409 SFN: V-0110 00G15 Mr. Karl V. Seyfrit Direct:or, Region IV Office of Inspection and Enforcement 611 Ryan Plaza Drive, Suite 100 y \\ Arlington, Texas 76102

Dear Mr. Seyfrit:

South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Re: ST-HL-AE-401 (December 28, 1979) In accordance with our letter of December 28, 1979, relative to the South Texas Project QA Program, we provide the following status report on the nine action items identified in subject letter. ACTION ITEM 1 - BROWN & ROOT WILL HOLD A SEMINAR ON JANUARY 4, 1980, TO REVIEW WITH CONSTRUCTION AND QC PERSONNEL THE FUNDAMENTAL I PHILOSOPHIES AND STANDARDS OF OUR QA PROGRAM WITH EMPHASIS ON THE ROLES PLAYE0 BY THE RGSPECTIVE PERSONNEL AND THE UNDERLYING PURPOSE OF THE PROGRAM, WHICH IS TO ENSURE THAT WE BUILD A PLANT WHICH CAN BE SAFELY OPERATED. STATUS: 1. A semin e was held January 4, 198.0 with Mr. Hall of your office present. l 2. The seminar was video taped and will be utilized in the future as part of the new Employee Indoctrination Program an-1 the Supervisors Training Program. p g 6 y W 90CW, 6 os## h 2 @Yg % Y seecM : [. cue d **3 ssco 3 05dhEsch S h G' i y oO, ) 50 G C11. 2

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Pg 2 3. Follow on sessions with smaller groups to immediately reinforce information delivered in the January 4, 1980 seminar and allow for dialogue between QC and Construction was held concurrently with refresher training on January 11 and January 14, 1980. 4. Follow-up seminars with each discipline will be held twice a year. The first follow-up session will be held on June 12, 1980 and every six months (6) thereafter. All actions have been implemented. ACTION ITEM 2 - PROCEDURE CHANGES WILL BE MADE TO CLARIFY THE USE OF FIELD REQUESTS FOR ENGINEERING ACTION (FREA'S) AND NON-CONFORMANCE (NCR'S). I RETRAINING FOR CONSTRUCTION AND QC PERSONNE,L IN THE USE OF THESE PROCEDURES WILL BE HELD ON JANUARY 10, 1980. i I i STATUS: An interim change was issued to STP-QAP-2.6 on January 9, 1980. Training in the procedure revision was held on January 11, 1980 with QC and Construction personnel. All actions have been implemented. ACTION ITEM 3 - LROWN & ROOT WILL ISSUE A WRITTEN POLICY WHICH EMBODIES THE PROCESS OF PROBLEM SOLUTIONS, AND LAYS OUT SPECIFIC STEPS TO BE TAKEN WHEN DISAGREEMENTS BETWEEN PERSONNEL ARISE SO THAT THOSE DISAGREEMENTS MAY BE PROPERLY DISPOSITIONED. THE POLICY WILL SPECIFICALLY ADDRESS THE FACT THAT THREATS WILL NOT BE TOLERATED, STATUS: A Project Management Procedure PGM-002 was published on January 7, 1980 to describe the steps to be taken in resolving differences between QA/QC I and Construction personnel. This procedure has been incorporated into a pamphlet titled, "The Quality Assurance Program on the South Texas Project" that was distributed to STP QA/QC Personnel and Construction Supervision en January 15 and 16, 1980. l Procedure PGM-002 was specifically addressed to current employees in training and will be brought to the attention of all new employees (Foremen through Project Manager). All actions have been implemented. 1 .~

? Pcgo 3 G. W. omuA J A ITEM 4 - A MANAGEMENT ASSESSMENT OF THE OVERALL QUALIFICATIONS OF THE BROWN S ROO ACTION QC PERSONNEL WILL BE COMPLETED BY THE

JANUARY, OUR PERSONNEL WILL BE THE CALIBER OF PERSONNEL.

INVOLVED IN THIS EVALUATION WITH BROWN & RO { l MANAGEMENT. Brown & Root has undertaken top manage-ment review of the qualifications and level of l STATUS: experience of all QA and QC personnel in South Texas Project and QAfQC management pers to assure.. hat qualified personnel can beChanges in personnel attracted and recognized. .have'been made and further personnel changesThis assessment 7 will be made as appropriate. l will be completed by February 6,1980 and wi results. ITEM 5 - THE THOROUGHNESS OF i ACTION AND PLACEMENT ACTIVITIES WILL BE INCREAS IMPLEMENTATION l EXPRESS DIRECTION TO BROWN & ROOT QA TION MANAGEMENT AND THE IMPLEMENTATION DIRECTION TO BE ENSURED BY PROCESS BY OUR CONSTRUCTION AND QA PERSONNEL, JOINTLY ACTING TO REPRESENT OUR INTEREST MAKING SURE OF COMPLETE THOROUGHNESS. A letter from Houston Lighting & Power 15, 1980 STATUS: to Brown & Root was written on January stating the expected minimum standards of perform-ance relative to concrete pre-planning and place-Increased involvement by HL&P ment activities. personnel in pre-planning meetings and safety-related concrete placement activities began onAll action l January 2, 1980. ITEM 6 - PROCEDURES WILL BE REVISED TO PROVIDE A CONTROLLED METHO ACTION ARY RETRAINING PRIOR TO SIGN-OFF OF THE POUR CARD.IN l. _..m..-.--, _,..m-_-_m_,,,,, _.m,. .,_,_,-.,.m___ ..-,_,_,,,._....-_,---w,._ _,-___._...,.._..__._,..-,r,_--,-_m.__,,-,_..

a w. on cAJa. Pcgo 4 STATUS: Quality Construction Procedure #A040KPCCP-3, Prepour Activities, was revised to include inspection criteria by Interim Change No. 1, dated January 7, 1980. Training for the Civil QA/QC personnel and for Construction Concrete personnel was conducted on January 2, 3 and 7, 1980. All actions have been implemented. ACTION ITEM 7 - MR. W. N. PMILLIPS AND TWO OTHER KEY MEMBERS OF OUR QC STAFF HAVE BEEN ASSIGNED TO THE JOBSITE TO FORTIFY OUR ROLE IN THE SHORT-TERM AND TO BE DIRECTLY AND VISIBLY INVOLVED IN THE WORK IN THE FIELD AND TO BETTER SUPPORT THE CONTINUING INVESTIGATION / INSPECTION BY THE NRC STAFF. WE WILL ALSO ADD ADDITIONAL PERMANENT STAFF TO THE JOBSITE IN 1980 AS RESOURCES TO CONTINUE IN A MUCH MORE INVOLVED AND PARTICIPATIVE ROLE TO ENSURE THE i l PROCEDURES ARE ADEQUATE IN THEMSELVES AND THAT IMPLEMENTATION IS THOROUGH. DISTINCTIVE IDENTIFI-CATION WILL BE PROVIDED FOR OUR PERSONNEL SO THAT THEIR PRESENCE WILL BE KNOWN TO ALL PARTIES EITHER OBSERVING OR PARTICIPATING IN THE WORK. STATUS: Messrs. W. N. Phillips, F. W. Stoerkel and T. K. Logan (all supervisory personnel) were temporarily assigned to the Project site on January 2, 198C. Special hard hats painted to l clearly identify HL&P QA personnel are currently in use. Two additional experienced civil personnel 1 experienced electrical, 1 experienced mechanical and 1 administrative technician will be added to HL&P site QA Staff as soon as possible. All action has been implemented. ACTION ITEM 8 - A PROGRAM OF REFRESHER TRAINING WILL BE IMPLEMENTED TO ENSURE CONTINUOUS REVITA-LIZATION OF THE KNOWLEDGE OF CONSTRUCTION AND QC PERSONNEL RELATIVE TO THEIR ASSIGNED DUTIES AND l PROCEDURES GOVERNING THEIR WORK. STATUS: Refresher training has been made a requirement of the Brown & Root training program. Refresher training was held on January 11 and January 14, 1980. Subsequent quarterly refresher training has been scheduled through the end of l 1980 and will be ongoing. l l e ,,-n----, ,.--,-_,-w, a n, v-m-w.

l .Pcg3 s' ~ G.W.o pmA JA ITEM 9 -AN ASSESSMENT WILL BE MADE STARTING ACTION WITH TOP LEVEL MANAGEMENT AND PROCEEDING THROUGH-OUT THE BROWN S ROOT ORGANIZATION TO DETERMINE THE CAUSE OF THE PERCEPTION OF HARASSMENT OR UNDUE CHANGES WILL BE MADE AS PRESSURE ON QC PERSONNEL. RESULTS OF THE ASSESSMENT ARE CLEAR AND CONCLUSIONS i WE EXPECT TO COMPLETE THIS ASSESS-CAN BE DRAWN. MENT WITHIN THIRTY DAYS. I An independent consultant experienced in STATUS: assessing attitudes and motivation of personnel on large construction projects is being utilized to perform this assessment through personal interviews As a result of preliminary and questionnaires. data obtained from this assessment personnel changes have been made in the construction and QA/QC The assessment will be completed by organization. February 6, 1980 and any additional organizational changes deemed necessary as a result of this assessment will be made. Implementation of this item is underway. If you have any questions regarding these matters, , please do not hesitate to contact me. Very truly yours, / ,' ) / G(_ GWO:rpvMessrs. E. A. Turner cc: D. G. Barker R. A. Frazar J. B. Poston (CPSB) R. L. Hancock (COA) M. L. Borchelt (CP&L) ....y....,_.._-_-,, _.-~.. _ _,,,,_,.,,..-,._.,,. ~ ___ _,.,_,,- __,,_,_,._,..,_ ___ _ y- --_,-c.,- ,,.,y --.-~,-. -, -.

c o' Houston 1 Applicants Exhibit No. 3 5l Lighting

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Com]an/v l gics s. '.U b Ekctnc Tow:r / A co W jil \\\\ RO Box (700 \\ Ws J hlli-i}lI Houston. Texas 77001 i g February 7, 1980 y N ST-HL-AE-417 SFN: C-0570 /, I6 ~ P '_2'. g?Nq$ M} Mr. Karl V. Seyfrit, Director ~.~ U. S. Nuclear Regulatory Commission 9. Office of Inspection and Enforcement t Region IV N, 611 Ryan Plaza Drive, Suite 1000 m its Arlington, TX 76012

SUBJECT:

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION RESPONSE TO NRC INSPECTION FINDINGS l l DOCKET NOS. 50-498/79-19 AND 50-499/79-19 NRC EXIT INTERVIEW, JANUARY 24, 1980 l

Dear Mr. Seyfrit:

This letter is to provide our responses to the principle matters identified in the NRC Exit Interview conducted at the site on January 24, 1980. 1. FAILURE TO TAKE CORRECTIVE ACTICN - SOME OF'THE SAME D8FICIENCIES RELATIVE TO CONCRETE PLACEMENT WHICH WERE IDENTIFIED IN THE JUNE, 1979, NRC IMMEDIATE ACTION LETTER ARE STILL OCCURRING. Corrective action as well as action taken to prevent a recurrence and the date that full compliance will be achieved is stated in correspondence reference below and attached. This item was initially identified to Houston Lighting & Power Company (HL&P) by the NRC in a meeting at Region IV Offices on December 21, 1979. On December 28, 1979, we met again in your office and discussed a nine point program to correct the, NRC identified problems. Subsequently, we sEnt ~ the NRC a letter dated December 28, 1979 (ST-HL-AE-401) i l ~. 2 l DKPE O F f o O ' ; \\ ' S O G Ty b

o. .n . t m.n. Page 2 detailing our specific actions. Action Item #5 addressed the recurring problems in concrete placements. Your letter of December 31, 1979, acknowledged receipt of our nine point corrective action program. Our letter of January 25, 1980 (ST-HL-AE-4 0 9 ) i l provides the status of that program. All actions on this item have been completed in accordance with our letter of January 25, 1980. l FAILURE TO TAKE CORRECTIVE ACTION - THERE IS NO l 2. EFFECTIVE TRENDING PROGRAM TO IDENTIFY AND CORRECT " ROOT" CAUSES OF DEFICIENCIES. SPECIFICALLY, THERE IS NOT AN ZFFECTIVE PROGRAM TO REVIEW AND ANALYZE NCRs, FREAs, ETC. FOR REPETITIVE OCCURENCES-l SUCH THAT " ROOT" PROBLEMS ARE IDENTIFIED AND CORRECTIVE ACTION IS TAKEN TO PRECLUDE REPETITION. l Corrective Action Taken A Trend Analysis Program for FREAs and NCRs is being developed which will: Establish a coding system to identify FREAs a. and NCRs by unit number, building location, subject, parent document number, and dispo-sition. This will be complete by February 15, 1980. b. Institute coding of current FREAs and NCRs and backfit all previously dispositioned documents. Coding will be effective February 15, 1980, and backfit will be complete by April 1, 1980. Modify existing FREA tracking program to c. allow selective sorting and trending programs. This will be complete by February 15, 1980. Action Taken to Prevent Recurrence A quarterly Trending Feport will be issued which will identify trends. These reports will be reviewed and all identified trends will be investi-gated for common causation. Remedial action will l i l l l

t i t.,,e, y i g.. g r. P...m t.ix.p.im Page 3 be taken to remove " root" causes of reocurring' deficiencies. Date Full Compliance Will Be Achieved Promptly upon completion of our review, we will advi-. the NRC of the date full compliance will be achieved. 3. FAILURE TO TAKE CORRECTIVE ACTION - IMPROPER CORRECTIVE ACTION TAKEN RELATIVE TO A SPECIFICATION VIOLATION CONCERNING REQUALIFICATION OF CADWELDERS. SPECIFICALLY, THE FSAR AND THE BROWN & ROOT.SPECIFICA-TION REQUIRE REQUALIFICATION OF CADWELDERS IF TWO FAILURES OCCUR OUT OF FIFTEEN CONSECUTIVE SAMPLES. CONTRARY.TO THE REQUIREMENTS, NCR SC-3155 WAS DISPOSITIONED TO REQUIRE THE SPECIFICATION AND FSAR TO BE CHANGED AND THE CADWELDERS WERE ALLOWED TO CONTINUE CADWELDING. Corrective Action Taken A detailed review of circumstances leading to the decision to revise or supplement requirements stated in the specification and the FSAR is underway. This review will be complete February 15, 1980. Corrective action will be determined by this review and implemented as appropriate. Action Taken to Prevent Recurrence Action taken to prevent recurrence will be determined after our review of this situation is complete. l l Date Full Compliance Will Be Achieved 1 Until our review scheduled for February 15, 1980, is complete, we will not have a firm completion date. 4. INSPEC"' ION AND TESTING PERSONNEL DID NOT MEET THE APPLICABLE PROCEDURE OR ANSI N45.2.6 QUALIFICATION REQUIREMENTS AT THE TIME OF THEIR CERTIFICATION. 1 i

f r.;.m i. -, ?. It a u npr. t A Page 4 Corrective Action Taken A. A review of the qualifications and certifica-tions of Brown & Root QA/QC personnel is being conducted in accordance with action item #9 of our nine point corrective action program. Education and experience is being verified by direct con-tacts with previous employers and schools. The preliminary results of the review indicates the following: (1) Brown & Root QC Inspectors were certified to ~ the then applicable Brown & Root QA Personnel Training Manual requirements prior to their performing any inspections. A revision to the Brown & Root QA Personnel Training Manual-STP Supplement dated October 1979 removed much of the latitude previously allowed. Personnel who do not meet the revised certification requirements are being retrained and recertified to insure that they meet the new requirements. All personnel will be recertified by May 15, 1980. 0 (2) Some Brown & Root QC inspectors were certified to perform inspections where their experience and educational background did not ueet the requirements of the upgraded qualification and certification program outlined in the Brown & Root QA Personnel Training Manual-STP Supplement dated October 1979. Investigations to date have identified only one individual for which there may be inadequate work experience or educational bac'kground. This individual will not be allowed to perform inspections until this matter is resolved. B. Pittsburgh Testing Laboratory (PTL) personnel files and certification records are being reviewed. i This review will be performed by PTL management and audited by Brown & Root to establish that the review was done properly. This review will be complete by February 29, 1980, and action will be taken to insure that PTL personnel are properly qualified. .g,

. e s l i, j,. K Y.cf ( 6Ty ts tr f Page 5 Action Taken to Prevent Recurrence The qualification and certification program will be specifically reviewed during HL&P surveillance activities on site and audited as part of the HL&P and Brown & Root Audit Program. Date Full Compliance Will be Achieved Action on item A. above will be complete by May 15, 1980. Action of item B. above will be complete by March 7, 1980. 5. INADEQUATE CONCRETE INSPECTION - NRC INSPECTORS IDENTIFIED UNWIRED SHEAR TIES AFTER QC SIGNOFF. Corrective Action Brown & Root-QA management held discussions with the entire QC organizations on February 5, 1980 to reemphasize that they are to take as much time as required to insure an accurate and thorough inspection. Action Taken to Prevent Recurrence HL&P QA and construction personnel will ensure by their direct involvement in preplacement and placement activities that adequate time is allowed for the inspection of placement areas prior to and during the placement of concrete to insure that conditions are acceptable. Date Full Compliance Will Be Achieved Full compliance was achieved on February '3, 1980. l 6. FAILURE TO IDENTIFY A NONCONFORMING CONDITION IN THAT REQUIRED RELATIVE DENSITY TESTS FOR CLASS I BACKFILL WERE NOT CONDUCTED FOR APPROXIMATELY TWO MONTHS. Corrective Action Taken HL&P issued a Site Discrepancy Memo on this subject on December 20, 1979. A new vibrating table was ...-.-.-.- -,._ ~.,

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n.' Pcga 6 received on December 31, 1979. By January 9, 1980, the backlog of tests were completed; no -failures of inplace densities were identified. Action Taken to Prevent Recurrence A memo was issued to QA/QC personnel on February 1, 1980 (SQA-3329) stating that all nonconforming conditions will be documented as soon as the are identified. Date Full Compliance Will'Be Achieved Full compliance was achieved on February 1, 1980. 7. INADEQUATE PROCEDURE FOR CLASS I BACKFILL DENSITY TESTS. LOCATION (DEPTH) THAT TESTS WERE TO BE CONDUCTED WAS NOT SPECIFIED TO ASSURE PROPER COMPACTION WAS OBTAINED THROUGH EACH LIFT. Corrective Action Taken A test program has been initiated on site, consisting of fifteen borings'at approximate locations shown on the attached map. Each boring will be made from existing backfill surface'to subgrade, with standard penetration tests (ASTM'D-1586) taken at ) 2'-6" intervals throughout each boring. The l recorded blow count, N, will be plotted against l depth and compared with theoretical counts to indicate whether proper density has been obtained. This. program is currently in progress, and results are expected by February 15, 1980. A copy of the results will be sent to NRC at that time. Action Taken to Prevent Recurrence l Procedures are being changed to specify depths for conducting in-place density tests. Action will re ~ i completed by February 15, 1980. Date Full Compliance Will Be Achieved Full compliance will be acheived by February 15, 1980. l

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15,. 18. r.*,;, (,cnjurh Pcga 7 8. FliILURE TO CONTROL SPECIAL PROCESSES a. RADIOGRAPHS 1. LINEAR INDICATIONS NOT PROPERLY IDENTIFIED OR DISPOSITIONED. 2. WALL THINNING NOT IDENTIFIED. ~ I 3. FILM ARTIFACTS NOT DOCUMEh"IED ON READER SHEET. I '4. WIRE / FOREIGN MATERIAL 5. NO PROCEDURE FOR FILM PROCESSING CONTROL. b. LIQUID PENETRANT RESULTS OF LIQUID PENETRANT EXAMIN; TION WERE NOT PROPERLY EVALUATED PER PROCEDURE. l Corrective Action Taken All radiography by sity QA/QC personnel has a. been stopped, g;;gggfgit4uey are under direct supervision of,ttEP level III E ngineering. Retraining and re-certification of all site NDE personnel was completed on February 1, 1980. A procedure for the control of film processing was issued on February 5, 1980. In the future, the shooter of an R/T film will not also do the film interpretation. This will be incorporated in the NDE Procedures as a procedural requirement. In addition, a review of all previous R/T films will be conducted and the appropriate corrective actions taken. All NDE procedures requiring revision will be revised by February 8, 1980. All radiographs will be again reviewed. This review will be complete by February 29, 1980. b. All B&R personnel certified in Liquid Penetrant l Examination will receive a refresher training program prior to their being allowed to perform further L/P examination. Retraining will be complete by February 8, 1980. l

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Page 8 Action Taken to Prevent Recurrence The NDE program will be specifically reviewed during HL&P surveillance and will be specially audited as part of the general HL&P and B&R audit program. Date Full Compliance Will Be Achieved All action will be complete by February 29, 1980. l 9. WELDING PERFORMED WITHOUT ADEQUATE PROTECTION FROM ADVERSE ENVIRONMENTAL CONDITIONS. l Corrective Action Taken This problem has been addressed by completely ( revising the Welder Training Program and adding a General Superintendent to coordinate work of the welders on the Project and to monitor their capabilities and progress, to initiate retraining where needed, l and to work closely with the welding engineers and welder training department. Additionally, a new Chief Project Welding Engineer reported for duty on February 4, 1980. He will work closely with construction, welder training, B&R corporate welding engineering, and QA/QC groups to institute programs to further improve welding performance. This new program will be implemented by February 15, 1980, including additional' training of exist-l ing welders on procedures / welding requirements. l Action Taken to Prevent Recurrence The new Welder Training Program will continue throughout the project. Implementation will be verified by HL&P QA surveillance or. site and through the HL&P and B&R audit program. Date Full Compliance Will Be Achieved Full compliance will be achieved by February 15, 1980. 10. FAILURE TO MEET REQUIREMENTS OF 10CFR50.55a (3) l RELATIVE TO THE QUALIFICATION OF WELDERS (IMPROPER l PENETRAMETER PLACEMENT). _. ~. - _.. _ _ _ _ _ _ _,. _. _ _ _

14

2. I'.u L r i w n.

s. Page 9 Corrective Action'Taken HL&P QA issued Site Concern Memo CM-077 on December 13, 1979, requiring the placement of penetrameters on the source side for all radiography where the inside is accessible. Source side penetrameters have been used on all welders' qualifications since January 3, 1980, and will be used from now on when welders are qualified by radiography. Action Taken to Prevent Recurrence The place of penetrameters will be reviewed during HL&P QA surveillance on site to determine that the procedures are being properly implemented. Date Full Compliance Will Be Achieved Full compliance was achieved on January 3, 1980. 11. LACK OF ADEQUATE DOCMIENT CONTROL Corrective Action Taken All controlled documents on file in the HL&P QA offices have been reviewed and brought up to date as necessary. The number of controlled documents kept in the HL&P QA offices is being evaluated to i determine that unnecessary documents.are not maintained. Action Taken to Prevent Recurrence The responsibility for document control of the HL&P QA sit.e offices will be reassigned to an Administrative Technician to be hired by HL&P QA. Date Full Compliance Will Be Achieved Full compliance will be achieved by March 1, 1980. I r l l i l

nu.im igjarg & nmer Gm;uny Page 10 12. HL&P QA SURVEILLANCE IS NOT DOCUMENTED IN ACCORDANCE WITH THE HL&P SITE QUALITY ASSURANCE PROCEDURES. Corrective Action Taken Verbal instructions were given to all HL&P surveill-ance personnel on January 24, 1980, relative.to the use of checklists to document all unsatis"actory conditions. Written instructions on this it~n were issued on February 1, 1980. Procec;ures will be revised to clarify the requirement to document all discrepancies noted during surveillance, including items being formally documented Ly others. All procedure revisions will be completed by February 25, 1980. Action Taken to Prevent Recurrence Implementation of the Site Quality Assurance Pro-cedures will be verified by HL&P audits. Date Full Compliance Will Be Achieved Full compliance will be achieved by February 25, 1980. 13. HL&P QA DID NOT PERFORM A COMPREHENSIVE ADDIT OF THE STP QA PROCEDURES AND CONSTRUCTION PROCEDURES. Corrective Action Taken a. The requirement in the South Texas Project Quality Plan to perform a corporate audit of B&R Construction annually had not been recognized. Audits of Brown & Root construction will be conducted annually, with 1980 audits scheduled I as follows: (1) Civil Construction Activities - March, 1980 (2) Mechanical Construction Activities - June, 1980 l (3) Electrical Construction Activities ^- August, 1980 ,y_,,- .w ---.v.--e r--y---y-m-- yr ---'w --'hv-w--'w-v--'-~ wr" N'

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HL&P audit procedures will be revised to state that procedures implementation will be verified by direct observation of work being performed in the field as well as by reviews of documentary evidence of procedural adherence. Action Taken to Prevent Recurrence HL&& management will implement an audit program to be performed by an outside consultant to assess the implementation and effectiveness of HL&P's QA Program for the South Tex *as Project. These audits will be conducted at least every 18 months. Date Full Compliance Will Be Achieved Full compliance will be achieved by March 15,

1980.

By March 1, 1980, an audit of the South Texas Project Quality Assurance Program will be scheduled. Should you have any questions regarding the above information, please contact us. Very truly yours, </* )rw.. =. Execut ve e-President Houston Lighting & Power Company GWO:rka/jow Attachments j cc: Messrs. E. A. Turner M. L. Borchelt (CP&L) 1 J. B. Poston (CPSB) R. C. Mecke (CPSB) R. L. Hancock (COA) M. C. Nitcholas (COA) D. G. Barker R. A Fraza7 W. N. Phillips G. B. Painter C. G. Thrash (Baker & Botts) M. D. Schwarz (Baker & Botts) H. S. Phillips (NRC) J. R. Geurts (B&R) C. W. Vincent (B&R) STP RMS

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.. e Com)3ny, \\ M ' ' Applicants' Exhibit No. 4 lI 'I i ~ !i L Electric Tower JI ---L L RO Box 1700 11 1 l i l L Houston. Texas 77001 February 28, 1980 ST-HL-AE-4 25 SFN: V-0110 g. W O Mr. Karl V. Seyfrit, Director oC({to go g U. S. Nuclear Regulatory Commission c Office of Inspection and Enforcement 6-ggy big l1 Region IV 2 g C SrJ -3 611 Ryan Plaza Drive, Suite 1000 9 t E *3" 3 S Arlington, Texas 76012 @ct

SUBJECT:

SOUTH TEXAS PROJECT ELECTRIC GENERA STATION DOCKET NOS. 50-498 AND 50-499 c) (P RE: ST-HL-AE-401 (December 28, 1979) ST-HL-AE-409 (January 25, 1980) Dear Mr. Seyfrit-We are providing the following update of our nine point action program as identified in our letter of December 28, 1979 and subsequent status report of January 25, 1980. ACTION ITEMS 1, 2, 3 5, 6, 7 and 8 - All actions have been implemented in accordance with the referenced letter of January 25, 1980. ACTION ITEM 4 - A MANAGEMENT ASSESSMENT OF THE OVERALL QUALIFICATIONS OF THE BROWN & ROOT QA AND QC PERSONNEL WILL B E COMPLETED BY THE END OF JANUARY, 1980, TO PROVIDE THE BASIS FOR UPGRADING THE CALIBER OF PERSONNEL. OUR PERSONNEL WILL BE INVOLVED IN THIS EVALUATION WITH BROWN & ROOT MANAGEMENT. STATUS: An assessment of the overall qualifications of the Brown & Root QA and QC personnel has been completed. To place additional emphasis on the overall qualifications of personnel being certified to perform inspection and testing for the South Texas Project, we plan to: 1. Continue the certification program started in October, 1979, for each individual and thus require higher minimum experience levels. 2. Reduce the ratio of less experienced entry level personnel to qualified inspectors in future employmbnt practices. M P TE O F g,my o4 0 ?'f o

l'w9m ight;ng 1Rmv Compy i Mr.' Karl V. Scyfrit, Dircctor Pcgo 2 2-28-80 3. Require confirmation of the qualifications of QA/QC personnel prior to certification. 4. Continue the QA/QC and construction refresher training programs initiated in January, 1980. 5. Improve internal communications within the QA/QC and construction organizations. 6. Continue to observe and evaluate the performance of project personnel and take required action necessary to strengthen and improve performance. 7. Implement a new salary adainistration program for QA/QC inspectors. 8. Require the discipline supervisors within QA/QC to be certified in all areas of their responsibi-lity. As a result of the review of all Brown & Root QA/AC personnel .(152) we have identified several individuals that had discre-pancies in either their education or work experience background. These individuals have not been allowed to continue their inspection responsibilities. We informed NRC Region IV personnel (Messrs. Seidel, Crossman and Hall) on February 21, 1980 that those personnel who do not as yet have confirmation of education and work experience are considered qualified to perform their respective fonctions based on previous examinations and documented proficiency. In order to ensure complete closure of the problem with verification of work experience and education, Nonconformance Report (NCR) H-0311 has been issued. In the future, pecsonnel qualifications will,be confirmed prior to certification. Actions originally identified as Action Item

1. 4 have been implemented.

ACTION ITEM 9 - AN ASSESSMENT WILL BE MADE STARTING WITH TOP LEVEL MANAGEMENT AND PROCEEDING THROUGHOUT THE BROWN AND ROOT ORGANIZATION TO DETERMINE THE CAUSE OF THE PER-CEPTION OF HARASSMENT OR UNDUE PRESSURE ON QC PERSONNEL. CHANGES WILL BE MADE AS RESULTS OF THE ASSESSMENT ARE CLEAR AND CONCLUSIONS CAN BE DRAWN. WE EXPECT TO COMPLETE ~ THIS ASSESSMENT WITHIN THIRTY DAYS. STATUS: .Timelapse, Incorporated, a professional consultant was commissioned to conduct an independent survey of both QA/QC and Construction personnel to determine the cause of the perception of harassment or undue pressure on site QA/QC personnel. This assessment concluded that the

= - Jkmtw.Iaftm5 & l'uw:r company Mr. Karl V. S2yfrit' DirGctor Pago 3 2-28-80 perception of harassment on QC personnel could have existed in the past because of instances of confronta-tion between Construction and QC personnel. Each of these instances in themselves was not especially signific' ant, but taken together it was possible that site QC perronnel perceived there to be a pattern of harassment and confrontation. The Timelapse assessment and further investigation and evaluation by the Contractor resulted in the following ~ actions by the Contractor: 1. Re-emphasis of the role of QA/QC.to the Construction Team. 2. Additional refresher training, seminars, meetings, etc. to strengthen the role and understanding of QA/QC. 3. A complete revamping of the Contractor's salary administration program for QA/QC at the Site. 4. An improved and more open communication by the QA/QC management at normal site meetings and with all levels of employees. Based upon the full implementation of our nine point action program, we would propose to begin the placement of safety related complex concrete on March 3, 1980. Very tjuly yours, ,'. T I w pr a gj/ Exec tiv ice President l WNP:rpv cc: Messrs. E. A. Turner W. N. Phillips, Jr. M. L. Borchelt (CPL) R. L. Waldrop J. W. Moore (CPL) L. D. Wilson J. B. Poston (CPSB) G. B. Painter R. C. Mecke (CPSB) J. D. Parsons R. L. Hancock (COA) M. D. Schwarz (Baker & Botts) M. C Nitcholas (COA) C. G. Thrash (Baker & Botts) H. R. Dean H. S. Phillips (NRC) C. L. McNeese J. R. Geurts (B&R) R. A. Frazar C. W. Vincent (B&R) D. G. Barker STP RMS L

y\\ CERTIFICATEOFSERVICE} I hereby certify that the foregoing document, and any l documents for which it is a cover letter, have been served on the following individuals and entities by deposit in the U.S. Mail, first class, postage prepaid on this S_J_4, day of , 1981. AA 4 T. B. Hudson, Jr. (/ Charles Bechhoefer, Esquire Docketing and Service Section Chairman Office of the Secretary Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Mrs. Peggy Buchorn. Dr. James C. Lamb Executive Director 313 Woodhaven Road Citizens for Equitable Utilities, In Chapel Hill, North Carolina 27514 Route 1, Box 1684 Brazoria, Texas 77422 Ernest E. Hill Pat Coy Lawrence Livermore Laboratory Citizens Concerned About Nuclear University of California Power P. O. Box 808, L-123 5106 Casa Oro Livermore, California 94550 San Antonio, Texas 78233 Edwin M. Reis Atomic Safety and Licensing Office of the Executive App'eal Board Panel Legal Director U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Atomic Safety and Licensing Brian E. Berwick Board Panel Assistant Attorney General U.S. Nuclear Regulatory for the State of Texas Commission P. O. Box 12548 Washington, D.C. 20555 Austin, Texas 78711 Mr. Jack Newman g at Lowenstein, Newman, Reis s & Axelrad 4' 9

c (go 1025, Connecticut Avenue, NW c

g Washington, D.C. 20036 6- ~ p\\F ~~ g%g1 .3 TH:4:D 9 3 y c) G}}